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7th Circuit Upholds Criminal Convictions Under OSHA

A recent case in the 7th Circuit, upholding the criminal convictions of two supervisors based on their falsification of health and safety records, serves as an important reminder that although uncommon, the Occupational...more

OSHA Clarifies That Alternative Digital Recordkeeping is Permissible

A recent standard interpretation letter dated April 29, 2025, addressed whether employers may use software-generated documents in place of the OSHA-required injury and illness recordkeeping forms, specifically Forms 300...more

The Heat is On: A First Look at OSHA’s Proposed Heat Standard

On July 2, 2024, OSHA released its long-awaited national heat illness and injury prevention standard as predicated in an earlier blog article. It applies to all employers conducting outdoor and indoor work in all general...more

OSHA Issues Guidance On Whether Musculoskeletal Treatments Are Recordable

In an enforcement memorandum dated May 2, 2024, OSHA provided guidance on whether musculoskeletal injuries are recordable under three treatment scenarios: first aid, Active Release Technique (ART) (massage that targets soft...more

Are Random Acts of Violence Recordable OSHA Injuries?

According to a recent OSHA standard interpretation letter, probably yes. In the May 17, 2023 letter, an employee drove the company vehicle on a public roadway between service calls. As the employee approached a car accident,...more

OSHA Issues Final Electronic Recordkeeping Rule

On July 17, 2023, OSHA released its final rule expanding its electronic recordkeeping and reporting requirements. As expected, the rule largely mimics OSHA’s 2022 proposal and takes effect January 1, 2024. The rule requires...more

The Interplay Between Ted Lasso and OSHA

WARNING: Spoiler alert! STOP reading now if you do not want to read spoilers which are used as examples to illustrate points in the blog article. As viewers know, Ted Lasso is a feel good show about an American college...more

Strategic Considerations When Producing Documents During An OSHA Inspection

During an OSHA inspection, the compliance officer will most likely request certain documents such as the manufacturer’s manual, safety and health policies, internal or external safety and health audits, videotapes, minutes...more

Release of New Proposed Rules: Electronic Submittal of Workplace Injuries and Illnesses to OSHA

On March 30, 2022, the Occupational Safety and Health Administration (OSHA) published new proposed rules regarding electronic recordkeeping requirements. Specifically, OSHA has sought to revise recordkeeping rules related to...more

When are Injuries from a Motor Vehicle Accident Recordable Under OSHA?

It is well-established that injuries and illnesses, such as those sustained in a motor vehicle accident that occurs during an employee’s normal commute time from home to work, are not work-related and thus not recordable...more

March 2nd Deadline to Electronically Submit 300A

The start of the New Year serves as a good reminder to covered employers that they must electronically submit 300A data on or before March 2, 2022, for the calendar year 2021. Covered employers include those with 250 or more...more

OSHA Withdraws COVID ETS for Healthcare

On December 27, OSHA announced it is allowing its ETS for healthcare facilities to sunset but that it would continue to work expeditiously to promulgate a permanent standard for coronavirus-related hazards. In its statement,...more

OSHA Publishes General Industry Emergency Temporary Standard

OSHA’s long-awaited general industry COVID-19 emergency temporary standard (“ETS”) was officially published today and became effective immediately for employers in those states without “state OSHA” plans. However, employers...more

OSHA Issues Enforcement Guidance For Electronic Recordkeeping Rule And Promises Aggressive Enforcement

As discussed in a previous blog, covered employers were required to electronically submit 300A data for the calendar year 2020 between January 2, 2021, through March 2, 2021. In a recent standard interpretation dated May 6,...more

Adverse Vaccine Reaction: An OSHA Recordable Event Or Not?

As more businesses reopen without restrictions and increased availability of vaccine supplies, many employers contemplate a mandatory vaccine policy. The decision turns on individualized facts to each organization, such as...more

OSHA Changes COVID-19 Recordkeeping Requirements For Employers (Again)

On May 19, 2020, the Occupational Safety and Health Administration (“OSHA”) published revised enforcement guidance detailing when employers must record COVID-19 illnesses. The new guidance reverses course on prior guidance...more

Recording Of Injuries/Illnesses Under OSHA

As mentioned in our last blog, the time for covered employers to post the OSHA 300A Summary is from February 1 to April 30. It is also a good time to revisit the issue of what kinds of injuries and illnesses should be...more

Soft Tissue Massage Considered First-Aid For OSHA Recordkeeping Purposes

Most employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses. However, minor injuries requiring only “first aid” generally do not need to be recorded. OSHA’s...more

OSHA Narrows Electronic Recordkeeping Rule

Last month, OSHA published its final rule revising the electronic recordkeeping requirements. The final rule rescinds the requirement for establishments with 250 or more employees to electronically file information from OSHA...more

OSHA’s Electronic Recordkeeping Rule Revisited

As previously mentioned in this blog, all covered employers under the new electronic recordkeeping regulation were required to electronically file their 2016 300A form by December 30, 2017. As of January 1, 2018, OSHA no...more

The Importance Of Reporting Workplace Injuries

There are some OSHA lessons to be learned and things to think about from the recent Third Department case in Silvestri v. New York City Transit Authority, 2017 N.Y Slip Op 06123 (August 10, 2017). In Silvestri, the Third...more

OSHA’S Electronic Recordkeeping Web Portal To Be Available On August 1, 2017

As part of OSHA’s new electronic recordkeeping rule previously discussed in prior blogs, certain employers will be required to electronically submit required injury and illness data from their 2016 Form 300A. OSHA believes...more

OSHA Proposes Delay Of The Electronic Recordkeeping Rule

As expected, OSHA proposed today to extend the compliance deadline from July 1, 2017 to December 1, 2017 for submission of electronic records under its new recordkeeping rule. This is not surprising as OSHA has yet to make...more

One DOL Drug Testing Rule Officially Gone – Is OSHA Next?

On May 10, the Department of Labor officially nullified a rule passed during the Obama administration that limited states’ ability to require mandatory drug testing for individuals applying for unemployment benefits. As...more

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